How to Stay Abreast of Constantly Changing Environmental Regulations

by Marilyn Herman and Wendy Clark

ASTM is now publishing a new Research Report on Reformulated Spark-Ignition Engine Fuel, D02: 1347, which condenses thousands of pages of federal and state laws and regulations into one easy-to-use reference tool. This document provides comprehensive information on federal and state requirements governing the use of reformulated gasoline (RFG) for ground vehicles equipped with spark-ignition engines. The RFG research report was written and continues to be maintained by the Reformulated Gasoline Task Force of Subcommittee D02.A on Gasoline and Oxygenated Fuels, which reports to Committee D02 on Petroleum Products and Lubricants.

The research report on reformulated gasoline enables gasoline refiners, marketers, government regulators, fuel additive suppliers, and other affected parties to stay abreast of constantly changing federal and state clean air programs. The research report is continually updated to incorporate the very latest changes and developments in federal and state reformulated gasoline programs, automotive requirements, and test methods.

The RFG research report describes various characteristics of reformulated fuels required for use by automotive vehicles in ozone nonattainment areas designated by the Clean Air Act Amendments of 1990 as well as additional areas opting into the reformulated gasoline program. The various characteristics of reformulated fuels described in the research report are legal requirements imposed by the U.S. Congress and regulatory agencies to lower exhaust and evaporative emissions from automotive vehicles.

The RFG research report also includes information on reformulated gasoline programs. Certain states, including California, Arizona, Nevada, Georgia, and Alabama require the sale of reformulated gasoline or cleaner burning gasoline to reduce ozone pollution. These state reformulated gasoline programs impose limits on vapor pressure, sulfur, olefins, aromatics, oxygen/oxygenates, and other properties (or combinations thereof), or have adopted certain provisions of the federal or California reformulated gasoline program.

Key highlights of the RFG research report are:

• Performance requirements for reformulated gasoline;
• Areas in the U.S. required to use reformulated gasoline;
• EPA Phase II Complex Model standards for federal RFG;
• California Phase 2 and Phase 3 reformulated gasoline requirements;
• ASTM, EPA, and CARB test methods for reformulated gasoline;
• EPA enforcement tolerances and CARB reproducibilities for RFG;
• EPA gasoline sulfur standards for reformulated and conventional gasoline; and
• State reformulated gasoline programs.

Reformulated Gasoline Task Force

ASTM Subcommittee D02.A on Gasoline and Gasoline-Oxygenate Blends has established the Task Force on Reformulated Gasoline. As part of its mission, the task force has prepared a research report providing comprehensive information on the properties and requirements of reformulated gasoline. Members of the task force include representatives from the U.S. Environmental Protection Agency (EPA), the California Air Resources Board (CARB), state regulatory agencies, refiners, automobile manufacturers, pipeline companies, fuel suppliers, and other stakeholders. To ensure the timeliness and accuracy of the information, federal and state regulators and members of industry provide input into the publication. The RFG research report is continually updated, and revisions are balloted within Subcommittee D02.A.

Federal RFG Program

Under the Clean Air Act Amendments of 1990, Congress established a major environmental program to reduce vehicle emissions of toxic and ozone-forming compounds. Congress requires the sale of reformulated gasoline in the nine largest metropolitan areas with the most severe summertime ozone levels, other areas reclassified as severe nonattainment areas, and areas choosing to opt into the RFG program.

The Clean Air Act established a two-phased program to implement the RFG program. Under the act, reformulated gasoline is required to contain a minimum average of two percent oxygen by weight, no more than one percent benzene, and no heavy metals. The retail sale of reformulated gasoline was required in areas requiring RFG beginning Jan. 1, 1995. Under Phase I of the program, EPA required a 15 percent reduction in volatile organic emissions and toxic air pollutants. Phase II performance standards, which took effect Jan. 1, 2000, require a 5.5 percent reduction in NOx, as well as further reductions in volatile organic emissions and toxic air pollutants.

Under the current program, refiners are required to certify reformulated gasoline in compliance with the parameters and requirements of the “complex model.” The complex model is a set of specifications and equations that predicts volatile organic compounds, oxides of nitrogen, and toxic air pollutant reductions based on the following parameters: aromatics, benzene, olefins, sulfur, oxygenate type and content, percent evaporated at 200ºF, percent evaporated at 300ºF, and vapor pressure.

Table 1 summarizes current EPA complex model standards for federal reformulated gasoline.

State Reformulated Gasoline Programs

In addition to the federal government, various states have established their own individual state reformulated gasoline programs. These programs often establish limits on such fuel properties as vapor pressure, sulfur, olefins, aromatics, oxygen/ oxygenates, and other properties, or incorporate certain provisions of the federal and/or California reformulated gasoline program. At the current time, California, Arizona, Nevada, Georgia, and Alabama have adopted regulations requiring the sale of cleaner burning gasoline or reformulated gasoline. These programs differ from state to state. Except for California, which requires the sale of RFG statewide, RFG is required in certain ozone nonattainment areas designated by state rules.

California RFG

California has adopted a major program requiring the sale of reformulated gasoline throughout the state. The California Reformulated Gasoline (CaRFG) regulations overall are more restrictive than those adopted by the EPA and establish a set of specifications and emission reduction requirements. The California Air Resources Board (CARB) has required the sale of reformulated gasoline program since 1992.

At the current time, all spark-ignition engine fuel for sale in California is required to comply with California Phase 2 Reformulated Gasoline (CaRFG2) regulations, which became effective March 1, 1996. California Phase 3 Reformulated Gasoline (CaRFG3) standards, which include prohibitions on the use of methyl tertiary-butyl ether (MTBE) in gasoline, were originally scheduled to become effective Dec. 31, 2002. However, in a recent action by the governor of California, California’s Phase 3 reformulated gasoline regulations have been postponed until Jan. 1, 2004. The California Air Resources Board is preparing a new rulemaking to implement the Governor’s action.

As shown in Table 2, CaRFG2 regulations impose limits on aromatics, benzene, olefins, oxygen, vapor pressure, sulfur, and distillation. Alternative formulations with different limits may be certified by CARB, based on motor vehicle emissions testing or the CARB Predictive Model.

Future Actions

Major new developments are likely to occur that will affect the composition and requirements of federal reformulated gasoline. Congress is currently considering new legislation to address various issues in RFG, including allowing states a waiver from the oxygen requirement in RFG, banning the use of MTBE, and mandating certain levels of ethanol and other renewable fuels as a replacement for MTBE.

While no final action has yet occurred, passage of this or other federal legislation will have a profound impact on the reformulated gasoline program. In addition, states will continue to evaluate whether to require some form of reformulated or cleaner burning gasoline as an emission reduction control strategy.

How To Order

Copies of Research Report D02: 1347, Research Report on Reformulated Spark-Ignition Engine Fuel may be obtained from Tracy Beckett, ASTM (610/832-9550).

For further information pertaining to the Reformulated Gasoline Task Force or federal and state fuel requirements, contact Marilyn J. Herman, president, Herman & Associates (phone: 202/362-9520). //

Copyright 2002, ASTM